Case Notes
Possession of "any" amount is sufficient; usable quantity standard not applicable, but de minimus doctrine may apply. 61 H. 291, 602 P.2d 933.
Though evidence insufficient to convict defendant of promoting a dangerous drug in the first degree, purged trial record contained substantial and admissible evidence that defendant knowingly possessed cocaine "in any amount". 80 H. 382, 910 P.2d 695.
Where defendant’s possession of .001 grams of methamphetamine did not threaten the harm sought to be prevented by this section, trial court did not abuse discretion by determining that amount of methamphetamine was de minimus under §702-236. 92 H. 130, 988 P.2d 195.
Where prosecution adduced substantial evidence that the cocaine residue in the pipe was visible to the naked eye and could be scraped out and smoked again, trial court did not abuse its discretion in ruling that defendant's infraction of this section was not de minimus within the meaning of §702-236. 93 H. 279, 1 P.3d 281.
Legislature intended to impose penal sanctions for constructive and actual possession of contraband items. 8 H. App. 610, 822 P.2d 23.
In subsection (3), the word "convicted" means "found guilty" and not "found guilty and sentenced". 93 H. 389 (App.), 4 P.3d 523.